The FCC’s inquiry into radiofrequency (RF) exposure limits and policies has generated broad response, as well as debate. Pong continues to play an active role in this process, weighing in on several topics of concern to users of cellphones and cases.
Who Regulates Cell Phone Exposure and Safety in the US?
Cell phones emit radiofrequency (RF) waves, a type of non-ionizing electromagnetic radiation (commonly called “cell phone radiation”). When a consumer holds or carries a mobile device in close proximity, the user’s head and body can absorb over half of the transmitted energy.
The Food and Drug Administration (FDA) typically prescribes safety standards for, and otherwise regulates, radiation-emitting devices (such as x-ray systems) and consumer products (like microwave ovens). For example, the FDA requires that all microwave ovens must meet radiation safety standards and bear a label explaining precautions for use. However, the FDA has never directly regulated the safety of cell phones or similar wireless devices, although they expose users to much more of the same microwave radiation, due to their more frequent use and closer proximity to human head and body . Ironically—although the Federal Communications Commission (FCC) sets and enforces exposure limits for cell phones and other wireless devices—the FCC is not a health and safety agency itself, and must rely on the FDA and the Environmental Protection Agency (EPA) along with other health agencies to help determine “safe” RF energy exposure limits that might sufficiently protect consumers.
Reassessing Current RF Radiation Standards
The FCC’s current exposure limit for the general public is 1.6 watts per kilogram (1.6 W/kg) in Specific Absorption Rate (SAR). SAR measures the rate of absorption of RF energy in human body. A cell phone’s SAR rating must not exceed 1.6 W/kg in order to receive FCC certification and be sold in the United States.
The current FCC exposure standards were adopted in 1996, and were based on animal behavioral studies in the 1980s. While these guidelines do set a maximum radiation exposure level to limit the amount of heat absorbed by the human body, cell phones can only meet the standards if they are placed at a certain distance away from the user’s body. For this reason, all cell phone manufacturers include warnings in their owner’s manuals to not wear or use the phone directly against the body but, rather, to keep them up to an inch away at all times.
The FCC standards have not been updated since 1996, while wireless technologies have been revolutionized and scientific research has progressed rapidly in the past 10-20 years. For example, the 1996 standards were adopted at a time when fewer than 20% of Americans had a mobile phone, cell phone use by children was rare and smart phones did not exist. Today, as of 2013, 91% of American adults and 78% of American teens have a cell phone, and around half devices are smartphones. Cell phones have become an essential part of modern life and cell phone usage has increased dramatically in recent years. Meanwhile, the body of scientific findings on the health effects of cell phone radiation is rapidly growing. According to the BioInitiative 2012, about 1800 new scientific studies were published between 2007-2012 reporting biological and health effects at exposure levels hundreds or thousands of times lower than current safety standards. The reported health effects include cancer, impaired brain and nervous functions, sperm damages, behavioral problems in children, to list a few. Scientific debate is ongoing on whether there is any potential health risks from cell phone use, especially long-term cell phone use and the use by children.
In August 2012, the Government Accountability Office (GAO) issued a report of its investigation into safety concerns related to mobile phones. The report noted that “the current FCC RF exposure limit may not reflect the latest research and testing requirements may not identify maximum exposure in all possible usage conditions”. The GAO Report called for the FCC to reassess and update its portable device radiation exposure and testing guidelines.
In March, 2013, the FCC commenced a formal Inquiry to determine whether there is a need for reassessment of the Commission radiofrequency (RF) exposure limits and policies. The Inquiry sought comments from the public and the industry on three key elements: the propriety of the existing standards and policies, possible options for precautionary exposure reduction, and possible improvements to the existing equipment authorization process related to RF exposure.
Different Stakeholders Expressed Different Opinions
As of the public commenting deadline of September 3, 2013, the Commission has received hundreds of reply comments from the wireless industry, expert organizations and public, including health, safety and environmental organizations, scientists, physicians and local governments. In their reply comments, different stakeholders expressed different, and often completely opposite opinions on various discussion topics of the Inquiry. But, although the GAO called on them to participate, neither the FDA nor the EPA has filed in the Inquiry.
Generally speaking, most health, safety and environmental organizations, physicians, scientists, and local governments  (thereafter called “health advocates”) filed comments urging FCC to strengthen its safety standards to provide sufficient protection of human health, especially for children and other vulnerable populations. On the other hand, the wireless industry  argued against any change to the current practice, except the suggestion to further loosen the exposure limit from 1.6 W/kg to 2.0W/kg .
Specifically, regarding the current state of science, health advocates believe that science is still inconclusive on whether cell phone use is safe or harmful to humans. There is a growing evidence of possible health risks from cell phone radiation and the long-term health effects of cell phone use are still unknown. In contrast, the wireless industry emphasizes that no scientific evidence established a causal link between wireless device use and cancer or other illness, and maintains that cell phones are safe.
In regard to information disclosure and safety warnings, health advocates generally support that consumers should receive more accessible and complete information regarding RF exposure. Conversely, the wireless industry believes that it is unnecessary to require mandatory disclosure or warnings regarding RF safety or encourage consumers to limit exposure to RF emissions.
When it comes to vulnerable population such as children, health advocates, especially the American Academy of Pediatrics (AAP) are concerned that current FCC standards do not provide sufficient protection to children and call for a new standard to protect the youngest and most vulnerable populations. On the contrary, the wireless industry claims that the Commission’s existing exposure standards are more than adequate, even for children.
In the matter of safety precaution, health advocates urge the FCC to encourage consumer awareness of possible RF exposure risks and related precautionary measures to reduce exposure. However, the wireless industry argues that it is not necessary to encourage any precautionary measures to limit exposure, and worries that promotion of precaution can impose a burden on the wireless industry.
Concerning the device certification procedures, the debate is mainly around the issue of proximity – the current FCC certification protocol allows the testing of mobile devices with a separation between the device and the body, instead of directly against the body, which may not identify the maximum exposure for the body . Health advocates generally believe that the current proximity allowances fail to reflect normal use, and should be changed accordingly to a “zero-distance” testing protocol because consumers often hold or carry their cell phones directly against their bodies. But the wireless industry maintains that the existing proximity restriction adequately protect public health and opposes any changes to the current measurement requirements.
As a technological leader in performance and safety focused mobile device cases, Pong Research contributed to the Inquiry with its expertise on the impact of wireless device accessories. Through its in-house and third-party testing, Pong brings up a unique point that “Cases Can Completely Change (and May Increase) Radiation Absorption” and recommends that the testing standards that already applied to belt clips and holsters should also be applied to cases.
The FCC’s review process is an important step in ensuring that wireless devices are safe for consumers, especially in light of the increase in numbers and usage of mobile devices, as well as changes in use scenarios and consequent exposure patterns.
 According to Electric Power Research Institute (EPRI) Field Measurement Study “Radio Frequency Exposure Levels for Smart Meters, a Case Study of One Model, February 2011”, the maximum/minimum RF power density level for cell phones at ear is 5000/1000 μW/cm2 compared to 200/50 μW/cm2 for microwave oven at 2 feet.
 For example, an Apple iPhone manual states: “iPhone’s SAR measurement may exceed the FCC exposure guidelines for body-worn operation if positioned less than 15 mm (5/8 inch) from the body (e.g., when carrying iPhone in your pocket).”
 According to the GAO Report, some consumers may use mobile phones against the body, which FCC does not currently test, and could result in RF energy exposure higher than the FCC limit.
 Such as EM Radiation Policy Institute, the International Brotherhood of Electrical Workers (750,000 members), the American Academy of Pediatrics (60,000 Medical Doctors), the American Academy of Environmental Medicine (235 doctors), the American Association for Justice (20,000 U.S. members), the City and County of San Francisco (population 800,000 plus), the National Association of Telecommunications Officers and Advisors (NATOA), the Environmental Working Group, Grassroots Environmental Education, the Town of Hillsborough, the Electromagnetic Safety Alliance, Om Gandhi PhD, Professor of Electrical and Computer Engineering, University of Utah; Cindy Sage MA, Co-editor of The BioInitiative Reports 2007 and 2012; Martin Blank PhD, Columbia University Department of Physiology and Cellular Biophysics; David Carpenter MD, Director of The Institute for Health and the Environment, SUNY Albany, the Center for Electrosmog Prevention; Martha Herbert MD, PhD, neurodevelopment specialist at Harvard Medical School; Magda Havas PhD, Trent University, Ontario; Devra Davis PhD, Environmental Health Trust.
 Such as CTIA (The Wireless Association), TIA, CEA, AT&T, Verizon, Motorola Solutions.
 CTIA Comment, P29, “the best available science indicates that the IEEE and ICNIRP 2.0 W/kg standards reflect the latest science and also adequately protects human health.” “The 2.0 W/kg standard makes possible improved network efficiency and coverage by allowing phones to operate at a higher power level when needed.”
 CTIA commented that encouraging further precautionary measures could result in increased infrastructure costs”, “any measures that would further restrict network operations, design or deployment would be burdensome” “Such efforts would offer no known benefit and would carry significant costs.”
 The specific minimum separation distance from the body is determined by the manufacturer (never to exceed 2.5 centimeters), based on the way in which the mobile phone is designed to be used. The GAO Report noted that “However, these testing procedures may not identify the maximum SAR for the body, since some consumers use mobile phones with only a slight distance, or no distance, between the device and the body, such as placing the phone in a pocket while using an ear piece”.
 Current testing procedures already account for accessories such as belt clips and holsters, which were pervasive in the 1990s, but not for cases, which did not exist then. Today, most consumers use cases, while belt clips and holsters are much less common.